The Air Safety Group is a voluntary organisation formed in 1964 whose aim is to monitor and improve safety in commercial air transport operations.

We are writing to you because of our concerns for the safety and welfare of cabin crew and passengers regarding the potential discrepancy between the maximum placarded weight of baggage in the overhead bins on all Airbus aircraft and the weight of bags actually loaded into those bins.

Due to changes in passenger habits and commercial pressures on airlines in recent years, there have been a number of fundamental changes in the loading of carry-on baggage. Many airlines now charge extra for baggage to be loaded into the hold whilst others have stringent restrictions on the amount of baggage that can be loaded in the hold free of charge i.e. normally only one piece with a maximum weight of 23kg. This has resulted in a substantial increase in baggage that operators are encouraging passengers to bring into the cabin and many airlines have no restrictions on the weight of this hand baggage. Indeed many airlines fail to actually weigh any of the baggage carried on board and this has meant overhead bins can routinely exceed their individual placarded weights.

This, we believe, could have a serious effect on the safety of passengers and crew in the event of an accident or incident: an example of which was the British Midland B737 Kegworth crash in 1989 where many of the injuries, and possibly fatalities, were caused by the overhead bins collapsing. There is the possibility of this happening again in the future in the unfortunate event of an aircraft having a very heavy landing or crash landing with overloaded overhead bins. Additionally, cabin crew have been suffering injuries both when assisting passengers to load their overweight carry-on baggage and when trying to close the overloaded bins.

We are seeking clarification from Airbus on behalf of cabin crew and passengers of the requirement of aircraft operators to adhere to the maximum placarded weights listed in these overhead bins. Our understanding is that the placarded weight is the maximum permitted and individual to each bin and therefore should not be exceeded under any circumstances. Perhaps you could advise whether, as the aircraft manufacturer, you would expect the placarded weights listed within each overhead bin never to be exceeded or whether there is any leeway in the maximum weights permitted? If there is no leeway, does this imply that operators must weigh all cabin baggage that is placed in the overhead bins and ensure even distribution of that baggage?

The Air Safety Group is a voluntary organisation formed in 1964 whose aim is to monitor and improve safety in commercial air transport operations.

We are writing to you because of our concerns for the safety and welfare of cabin crew and passengers regarding the potential discrepancy between the maximum placarded weight of baggage in the overhead bins on all Boeing aircraft and the weight of bags actually loaded into those bins.

Due to changes in passenger habits and commercial pressures on airlines in recent years, there have been a number of fundamental changes in the loading of carry-on baggage. Many airlines now charge extra for baggage to be loaded into the hold whilst others have stringent restrictions on the amount of baggage that can be loaded in the hold free of charge i.e. normally only one piece with a maximum weight of 23kg. This has resulted in a substantial increase in baggage that operators are encouraging passengers to bring into the cabin and many airlines have no restrictions on the weight of this hand baggage. Indeed many airlines fail to actually weigh any of the baggage carried on board and this has meant overhead bins can routinely exceed their individual placarded weights.

This, we believe, could have a serious effect on the safety of passengers and crew in the event of an accident or incident: an example of which was the British Midland B737 Kegworth crash in 1989 where many of the injuries, and possibly fatalities, were caused by the overhead bins collapsing. There is the possibility of this happening again in the future in the unfortunate event of an aircraft having a very heavy landing or crash landing with overloaded overhead bins. Additionally, cabin crew have been suffering injuries both when assisting passengers to load their overweight carry-on baggage and when trying to close the overloaded bins.

We are seeking clarification from Boeing on behalf of cabin crew and passengers of the requirement of aircraft operators to adhere to the maximum placarded weights listed in these overhead bins. Our understanding is that the placarded weight is the maximum permitted and individual to each bin and therefore should not be exceeded under any circumstances. Perhaps you could advise whether, as the aircraft manufacturer, you would expect the placarded weights listed within each overhead bin never to be exceeded or whether there is any leeway in the maximum weights permitted? If there is no leeway, does this imply that operators must weigh all cabin baggage that is placed in the overhead bins and ensure even distribution of that baggage?

Yours sincerely

Captain Russ Williams FRAeS
Chairman, Air Safety Group

12th March 2010

Mr Paul Clark MP
Parliamentary Under Secretary of State
Department for Transport
Great Minster House
76 Marsham Street
London SW1P 4DR

Dear Paul,

AIRCRAFT MAINTENANCE ENGINEERS WORKING HOURS

We are writing to you to express our concerns about the allowable duty hours of Aircraft Maintenance Engineers (AMEs).

Unfortunately, with the continuation of the E U Working Time Directive Opt-out clause, those AMEs who so choose, either under their own volition or through the 'encouragement' of their company, have no duty hour limits imposed and have been known to work excessive hours each week (up to 80 – 85 hours) for several weeks at a time. This, we believe, is far in excess of what can be argued as reasonable or safe.

Further to this, there is a current shortage of qualified AMEs, which will become even more critical and exacerbated if/when the current economic downturn improves. Operators will be forced to work their AMEs to the limit and this will have the obvious potential for fatigue related safety incidents to become increasingly evident. In any major safety incident/accident the flight crew's previous duty and flying hours, together with their rest periods, are examined in detail and published in the subsequent accident report. Rarely does the investigation publish the hours worked by the last AME to provide servicing or maintenance on the aircraft, in order to establish whether or not an AME fatigue related error might have been a contributory or causal factor.

Aircraft maintenance and servicing is, therefore, a 'Safety Critical' occupation with a direct link in the chain of events that can lead to a major aircraft safety incident/accident. Yet those AMEs are permitted to work just as long as they wish with no restrictions whatsoever, other than those that may be imposed by those responsible operators fortunate enough to have adequate numbers of AME staff employed. As such, and in line with Flight and Cabin Crews and Air Traffic Controllers, we would strongly recommend that AMEs duty hours and rest requirements be strictly limited and controlled. This is particularly the case with licensed engineers who, in exercising the privileges of their licence to issue Certificates of Release to Service, are legally certifying the airworthiness of EU Commercial Air Transport aircraft.

The UK Air Navigation Order makes it an offence for an AME to exercise their licence whilst fatigued. Yet when under a high level of commercial pressure to rectify a technical fault on an aircraft in order to urgently return it to service, and there being no-one else available, it is almost impossible for any individual to simply walk away, even when they know they are feeling too fatigued to safely continue their work.

We note the recent limitation on working hours imposed on the Medical profession and believe the road charity BRAKE is currently lobbying for restrictions to be imposed on Taxi drivers. We firmly believe that a legally binding work and rest scheme must be the long term aim for controlling AME working hours. There are a number of documents published (CAA Paper 2002/06 by Simon Folkard and ICAO Guidance Document 9824) that provide adequate guidance to mitigate the effects of AME fatigue but they are not compulsory and can be, and are, largely ignored.

Perhaps you could advise how we may progress this issue? The immediate and perhaps obvious initial step would be to prevent those AMEs working on and servicing EU Commercial aircraft from being able to opt out of the Working Time Directive. At least then the 48 hour average working week would apply and serve to protect both the AMEs and the public who fly in the aircraft they maintain.

Yours sincerely

Mr R Gifford,
Executive Director PACTS

Captain R Williams FRAeS,
Chairman, Air Safety Group

18th September 2009

Mr Brian Simpson MEP
European Parliament
Brussels

Dear Mr Simpson,

AIRCRAFT MAINTENANCE ENGINEERS (AME's)

The Air Safety Group, a voluntary organisation established in the 1960's to improve the safety of Commercial Aviation, has a number of major safety concerns. I have previously exchanged emails with you in relation to the Flight and Duty Time Limitations issue and the current state of EU OPS1 Subpart Q, which continues to be one of our main safety concerns. Another issue now coming increasingly to the fore is that of the allowable duty hours of Aircraft Maintenance Engineers (AME's).

Through your efforts in recent years in compiling Subpart Q, all EU Flight and Cabin Crew do now have specific duty and flying hour limits governing their day to day operations, albeit at present without the benefit of current essential scientific and medical evidence being incorporated. Unfortunately, with the continuation of the Working Time Directive Opt-out clause, those AME's who so choose, either under their own volition or through the 'encouragement' of their company, have no such duty hour limits imposed and have been known to work excessive hours each week (up to 80 – 85 hours) for several weeks at a time. This, we believe, is far in excess of what can be argued as reasonable or safe.

Further to this, there is a current shortage of qualified AME's, which will become even more critical and exacerbated if/when the current economic downturn improves. Operators will be forced to work their AME's to the limit and this will have the obvious potential for fatigue related safety incidents to become increasingly evident. In any major safety incident/accident the flight crew's previous duty and flying hours, together with their rest periods, are examined in detail and published in the subsequent accident report. Rarely does the investigation publish the hours worked by the last AME to provide servicing or maintenance on the aircraft, in order to establish whether or not an AME fatigue related error might have been a contributory or causal factor.

Aircraft maintenance and servicing is, therefore, a 'Safety Critical' occupation with a direct link in the chain of events that can lead to a major safety incident/accident. Yet those AME's are permitted to work just as long as they wish with no restrictions whatsoever, other than those that may be imposed by those responsible operators fortunate enough to have adequate numbers of AME staff employed. As such, and in line with Flight and Cabin Crews and Air Traffic Controllers, we would strongly recommend that AME's duty hours and rest requirements be strictly limited and controlled. This is particularly the case with licensed engineers who, in exercising the privileges of their licence to issue Certificates of Release to Service, are legally certifying the airworthiness of EU Commercial Air Transport aircraft.

The UK Air Navigation Order makes it an offence for an AME to exercise their licence whilst fatigued. Yet when under a high level of commercial pressure to rectify a technical fault on an aircraft in order to urgently return it to service, and there being no-one else available, it is almost impossible for any individual to simply walk away, even when they know they are feeling too fatigued to safely continue their work.

We note the recent limitation on working hours imposed on the Medical profession and believe the road charity BRAKE is currently lobbying for restrictions to be imposed on Taxi drivers. We firmly believe that a legally binding work and rest scheme must be the long term aim for controlling AME working hours. There are a number of documents published (CAA Paper FOLKHARD Report and ICAO Guidance Document 9824) that provide adequate guidance to mitigate the effects of AME fatigue but they are not compulsory and can, therefore, be largely ignored. I would mention that, as a professional pilot, I would not be willing to operate an aircraft that I knew had been serviced overnight by an AME working up to their 80th hour or more in the last 6 or 7 days. I am sure that same AME would be loathe to fly in my aircraft had I just worked that number of hours!

Perhaps you could advise how we may progress this issue and to who it should be addressed? The immediate and perhaps obvious initial step would be to prevent those AME's working on and servicing EU Commercial aircraft from being able to choose to opt out of the Working Time Directive. At least then the 48 hour average working week would apply.

Following an increasing number of reports of interference problems in the mid 1990's caused by the use of mobile telephones onboard aircraft, I was instrumental, as Head of Flight Operations (Policy and Regulations) of the Safety Regulation Group, in banning their use. Since that time there have been numerous other reports where their unauthorised use has posed interference to onboard navigation equipment and other systems. On February 5th of this year I noted an MOR (Number 200801349) filed relating to a B747 of British Airways that on 3 occasions exceeded the set airspeed on autopilot by an uncommanded increase in power on all four engines and it then turned the wrong way following a direct track to the next waypoint. This was established as being caused by an unauthorised use of a mobile telephone in Business Class leading the Captain to have to intervene to insist it be switched off, whereupon the aircraft behaved normally.

After the B777 accident at Heathrow, I wrote to Flight International (letter published on 4th March 2008 issue) posing the question of possible interference by one or more mobile telephones to the fuel control units and/or software on the accident B777, which, in the light of the above B747 incident, did seem to us to be a distinct possibility.

The Air Safety Group has serious concerns at the apparent headlong rush currently evident to satisfy the demand for almost unlimited use of mobile telephones onboard commercial aircraft and we hope sincerely that the certification processes will ensure their safe introduction and utilisation. We recently presented our concerns to the Parliamentary Advisory Council for Transport Safety (PACTS) - we currently advise them on Aviation Safety issues - and by way of follow up would like to receive the AAIB views on this matter.

I am sure the AAIB Investigation would have established whether or not any mobile telephones were actually operating during the final stages of the accident flight. Could you possibly advise if there were any Mobiles or other PEDs switched on inside the B777 at the time immediately leading up to the accident? If there were, then I assume it would be almost impossible to establish where, precisely, on the aircraft they were positioned, bearing in mind that the passengers may not always stay in their originally allocated seats throughout the flight.

From the AAIB Interim Report it is noted that HIRF and EMI possible interference has been discounted following tests 'well in excess' of published maximum emissions. From my recollection of the mid 1990's we were very concerned at the random nature of the interference being experienced, which depended largely upon which source of emission was being generated and precisely where that source was positioned within the aeroplane, together with the potential for emissions being combined to produce anything up to a tenfold increase on occasion. This random nature was almost impossible to replicate during testing inside an aircraft on the ground.

To help us understand a little more, and going back to the aforementioned B747 incident, would the FDR and QAR on that aircraft, for example, have registered the increased, and uncommanded, fuel flow resulting in the increased airspeed on the three occasions? I assume that they would, but would the cause have been evident as being due to HIRF/EMI or simply all four throttles being moved forward, for whatever reason, and exceeding the autopilot set airspeed? How could that exceedance have been generated and what piece of equipment could have been interfered with to cause that specific problem? Whilst satellite navigation equipment does appear to be more readily prone to interference from mobile telephones (causing the aircraft to turn the wrong way), the fact that engine fuel controls also appear to be susceptible is of great concern.

I would very much welcome your comments and assurances that the AAIB Investigation has complete confidence that no such HIRF/EMI interference could possibly have contributed in any way to this accident. One cannot help but wonder whether it might now perhaps be prudent to initiate further research into this phenomena?

Sir, As the security risk has recently been downgraded and the travelling public is adapting to a far more stringent security regime than ever before, now would seem to be an appropriate time to reconsider the whole subject of what is allowed to be carried into the aircraft cabin.

For many years the Air Safety Group has been concerned at the increasing amount of carry-on baggage, including large numbers of duty-free bottles, that seem to have become the norm. Recent actions of charging for checked in baggage by at least one low-cost carrier have made the situation even worse.

We suggest two courses of action that should now be introduced as permanent measures. First, all future carry-on cabin baggage should be strictly limited to one item per person, the maximum size being that currently allowed (0.16m x 0.35m x 0.45m) and secondly, intended purchases ordered at the airport of departure and/or on the aircraft, in particular of duty-free bottles, should be collected at the final destination airport.

These practical measures to reduce carry-on baggage would involve no change to airport facilities. Insisting that "duty-free" be purchased or collected on arrival would maintain the airlines’ sales with the bonus of them not having to carry a large number of bottles and other items throughout the flight. The reduced amount of cabin clutter would improve both the comfort and overall safety of the passengers, especially during an emergency evacuation.